There’s no disputing the extreme challenges posed to DRD as a marginal miner in developing countries like South Africa and Papua New Guinea by the growing lobby internationally for mining that is more environmentally responsible – lobbies that have resulted in changed and changing, increasingly tougher legislated environments.

    “We’ve never argued against the logic for environmentally responsible mining,” says Lubbe. “The big challenge for us was how we could afford to apply it across a suite of operations others had given up on as unprofitable and stay in business.”

    When the company has said that its most responsible course of action is to stay in business, this has sometimes been misinterpreted as an excuse to serve only the demands of shareholders and do as little as possible in respect of anything else.

    “The fact is, responsible environmental management costs, and if a company can’t stay in business – generating revenues, employing people, paying taxes, and prefunding rehabilitation, as well as creating value for shareholders – it can hardly be said to be responsible, in our view,” says Lubbe.

    The company has been guided thus far by two principles: staying the right side of the law and application of the BATNEEC approach. It has been made aware – sometimes painfully – that these are not always perceived to be enough by some observers.

    Lubbe believes DRD’s latest thinking and practice on environmental matters – fuelled, he freely admits, by its improved operating and financial profile over the last couple of years – reflects a solid shift from doing simply what is necessary to doing what is desirable.

    “Our point of departure is integration of environmental management into strategic and business planning; moving beyond compliance to adoption of best practice, having taken cognisance of global trends.”

    Consultation required by law is broadening, increasingly, into participative decision-making with regulators, communities and other interested and affected parties.

    “With this, there’s a quid pro quo in the form of joint responsibility and accountability,” says Lubbe. “The ball is back in the company’s court, however, when it comes to education, training and creating awareness of environmental and related issues, both amongst employees and in the broader community.”

    Effective environmental management at operational level goes beyond giving action to the spirit and intent of environmental management programmes approved by the relevant authorities, he says.

    Risk identification and amelioration, regular auditing to assess compliance with and effectiveness of policies and practices, prudent management of renewable and non-renewable resources are all critical considerations.

    “Inevitably, debate around most matters related to effective environmental management – specifically the thorny issue of rehabilitation – returns to the cost,” Lubbe insists.

    Responsibility here, he holds, begins with informed anticipation of what rehabilitation costs are likely to be and with making adequate provision for meeting them. At DRD, a board of trustees, reporting to the board of directors, manages environmental trust funds for each of the company’s operations.

    With a total liability estimated at $17.9 million and some $12.1 million already vested within the various funds, DRD is amongst the best positioned in the South African mining industry to fund its rehabilitation obligations, says Lubbe.